Policy paper

Conflict of interest policy for disciplinary panel members

Published 21 October 2026

Applies to England and Wales

This policy should be read alongside the disciplinary and sanctions procedure (the procedure).

We, the Building Safety Regulator (BSR), follow this procedure to determine whether:

• a registered building inspector (RBI) is guilty of professional misconduct
• a registered building control approver (RBCA) has contravened the professional conduct rules
• sanctions are appropriate and what level they should be

Disciplinary panel members must follow the code of conduct. To meet their obligations under the code and to ensure that disciplinary proceedings are conducted in a fair and consistent way, disciplinary panel members must declare any actual, potential, or perceived conflicts of interest.

This policy explains:

• what we mean by conflicts of interest
• how and when interests must be declared
• how we manage conflicts of interest
• how to raise a concern about a disciplinary panel member’s conflict of interest

Who this policy applies to

This policy applies to all individuals appointed as disciplinary panel members. This includes:

• legally qualified chairs
• lay members
• professional members (registered building inspectors)
• panel members acting as disciplinary officer at stage 1 of the procedure

In this policy, references to: 

• panel members mean disciplinary panel members including panel members acting as disciplinary officer at stage 1 of the procedure
• ‘respondents’ means RBIs and RBCAs whose conduct is being considered under the procedure
• ‘conflicts of interest’ or ‘conflicts’ includes actual, perceived, and potential conflicts of interest

This policy does not apply to other BSR employees or contractors involved in the disciplinary and sanctions procedure. This policy does not apply to other BSR employees or contractors involved in the disciplinary and sanctions procedure.

What we mean by conflicts of interest

A conflict of interest arises when a panel member’s interest could impair or influence their ability to carry out their role.

Conflicts of interest may arise where:

• a panel member or a person connected to them could benefit
• a panel member has a loyalty to a third party that conflicts with their role in the disciplinary and sanctions process

Panel members must declare:

• any actual conflicts of interest
• interests that could become a conflict of interest
• interests that could be perceived as a conflict of interest

Our approach to conflicts of interest

We’re committed to making sure interests are identified, declared and managed appropriately. When dealing with conflicts of interest, we will:

• recognise that confidence in disciplinary decisions depends on the absence of any reasonable perception of bias
• use a consistent approach so similar conflicts are dealt with in similar ways across cases
• act proportionately, recognising that not every interest requires the same response
• encourage the early declaration of conflicts of interest
• keep accurate records of every declared conflict, any actions agreed and the reasons for it
• be transparent with respondents about any conflict declared in their case and how it has been dealt with, consistent with data protection law

Types of interests and relationships

Panel members must consider whether they have any interests or relationships that could affect, or be perceived to affect, their impartiality.

This section includes examples of interests and relationships that panel members should consider, but the list is not exhaustive.

Financial interests

Financial interests may include:

• all paid employment, including full-time or part-time employment, non-executive positions, consultancies and self-employment
• gifts, hospitality or other benefits offered in connection with the panel member’s role
• direct or indirect ownership, shareholding, or financial interest in a respondent or in an organisation closely connected with a respondent
• current or past employment, consultancy or contracting by a respondent or their professional advisers
• past, current or anticipated commercial relationships that would be materially affected by the outcome of a case

Professional interests

Professional interests may include:

• all unpaid work, including volunteer positions and trusteeships
• prior involvement as an investigator, complainant, witness or adviser in a case investigated under the procedure or in a related matter
• prior professional involvement with the building, work or decision that led to the allegations
• membership of or employment by an organisation with a direct interest in the outcome of a case
• membership of any professional body or grouping with interests, objectives, or activities relevant to an allegation

Political and personal interests

Political and personal interests may include:

• publicly expressed views, campaigning activity or personal convictions on a specific or related case that could reasonably raise concerns about impartiality
• personal circumstances that create a direct personal stake in the outcome, for example, where the panel member or a family member lives in, works in, or is otherwise affected by a building involved in a case
• an elected or appointed political office with an interest in, or that could be affected by, the outcome of a case relating to the same geographical area or sector

Relationships

Personal or professional relationships may include:

• family or close personal relationships with a respondent, witness, representative, or their employees
• business partnership, joint venture or consortium with a respondent, or with anyone connected to them
• long-standing professional or social connections that a reasonable third party would consider relevant

People connected to a panel member

An interest held by a person or organisation connected to the panel member can cause a conflict of interest in the same way as an interest held by the panel member. This may include interests held by:

• a child, stepchild, grandchild, parent, brother or sister of the panel member
• the spouse, unmarried partner or civil partner of the panel member, or of any person listed in the previous point
• people in a business partnership with the panel member, or with any person listed in the previous points
• any company, business, trust or organisation in which the panel member, or any person connected to them, holds an interest through ownership, control, beneficial entitlement or material influence
• any person or organisation with which the panel member, or a person connected to them, has a close or long-standing professional, commercial or personal relationship

If a panel member is unsure about whether a personal interest or an interest held by a connected person should be declared, they should make a declaration.

How and when to declare interests

Panel members must declare their interests:

• on appointment to the BSR disciplinary panel
• before accepting any role in a disciplinary case
• as soon as possible after the panel member becomes aware of any new circumstance that may cause a conflict of interest, even where the case is already underway

We will also conduct an annual review of the register of interests. As part of that review, panel members will be asked to confirm the accuracy and completeness of their declarations.

Where a case is already underway and a panel member becomes aware of any new circumstance that may cause a conflict of interest, they must notify a member of the disciplinary and sanctions team as soon as possible.

Disciplinary proceedings may be paused or adjourned where necessary to allow the concern to be assessed and determined.

Panel members must complete a form to declare their interests. The form sets out:

• the nature of the interest
• the source of the interest, including any relevant person, organisation or event
• whether the panel member considers the interest to give rise to an actual, potential or perceived conflict, and why
• the date the panel member first became aware of the interest
• any steps the panel member has already taken to avoid the interest affecting their work, and any they propose to take

Panel members must:

• send their completed forms to dasp@buildingsafety.gov.uk
• keep a copy of the forms for their own records
• keep a copy of the disciplinary and sanction team’s acknowledgment of receipt of the declaration

How we manage interests

Declarations are made to the determining officer. In most cases, this will be a member of BSR’s disciplinary and sanctions team responsible for carrying out the disciplinary and sanctions procedure.

The way we manage the conflict will depend on its nature and extent. The determining officer will:

• assess the nature and extent of the conflict
• assess the risk or threat to the panel member’s professional judgment
• decide whether the conflict is serious
• decide whether to appoint or maintain the appointment of the panel member to the panel

In deciding whether a conflict of interest exists, the determining officer will consider all relevant circumstances. The existence of an interest or previous connection alone may not amount to a conflict of interest. Where the determining officer decides that the interest presents risk to the panel member’s actual or perceived impartiality, or where this risk cannot be reasonably ruled out, the panel member will be withdrawn from the case. Otherwise, the panel member may continue to participate.

We keep a record of the declaration and tell the panel member about the decision.

A determination is not fixed in time. The panel member and the determining officer remain under an ongoing duty to notify the disciplinary and sanctions team any new or changed interest as it arises.

How to raise a concern about a conflict of interest

Respondents and other members of the public may, at any stage, raise a concern about a conflict of interest to a panel member. Concerns should be emailed to dasp@buildingsafety.gov.uk.

If proceedings have already begun, respondents should raise concerns as soon as possible with a member of the disciplinary and sanctions team. The proceedings may be paused or adjourned were necessary to allow the concern to be assessed.

The reporting individual does not need to prove that an actual conflict of interest exists. It is enough to set out the facts that might lead a reasonable person to believe that a conflict of interest exists or is likely to occur.

Any concerns raised by the public are determined under the process set out in this policy.

Where a concern is raised by a respondent, a summary of the determination will be recorded and sent to them. The summary will explain what action has been taken and what it means for the case. 

Failure to declare interests

A failure to declare relevant interests is a serious matter. Where we become aware of a suspected breach, we will investigate the matter and may:

• replace the disciplinary panel member concerned where a case is ongoing
• act in accordance with the disciplinary panel member complaints process

Where the person concerned is an RBI, failing to declare relevant interest may amount to professional misconduct and may be dealt with under the disciplinary and sanctions procedure. 

Any panel member who becomes aware of a breach of this policy must report it to dasp@buildingsafety.gov.uk as soon as possible.

Register of interests

To keep a complete, accurate, and auditable record of declarations, we will maintain a secure electronic register of interests for all panel members. The register will record:

• a written description of each conflict, including the relationships involved
• any assessments and determinations made in relation to a declaration
• who was the determining officer of a particular declaration

We will review the register annually and update it on any change.

Information in the register is processed in accordance with data protection law and used only for the purposes of this policy and the proper exercise of the disciplinary and sanctions procedure. 

Individual register entries are available for inspection to those with a legitimate need to see them, such as any appellate body.

Reasonable adjustments

Under section 1.3 of the disciplinary and sanctions procedure, any individual involved in the process may request reasonable adjustments to support their participation. This includes reasonable adjustments for the declaration of interest or raising of concerns about a conflict of interest. All requests will be given due consideration.

Reasonable adjustments can be requested by contacting dasp@buildingsafety.gov.uk.

Review of this policy

BSR’s professional standards manager will review this policy regularly, and on any significant change to the disciplinary and sanctions procedure or the code of conduct. The review will consider lessons learned from the implementation of this policy.